Decision Document
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Intensive Farming Decision Document Bespoke permit We have decided to grant the permit for Wotherton Farm operated by Mr Thomas Gittins The permit number is EPR/AP3238NW/A001 We consider in reaching that decision we have taken into account all relevant considerations and legal requirements and that the permit will ensure that the appropriate level of environmental protection is provided. Purpose of this document This decision document: • explains how the application has been determined • provides a record of the decision-making process • shows how all relevant factors have been taken into account • justifies the specific conditions in the permit other than those in our generic permit template. Unless the decision document specifies otherwise we have accepted the applicant’s proposals. Structure of this document • Key issues • Annex 1 the decision checklist • Annex 2 the consultation and web publicising responses Key Issues 1. Introduction The installation consists of four poultry houses with places for 200,000 birds. It is located near Wotherton in Shropshire at grid reference 328130,300829. Birds will be brought to the installation from a hatchery and kept at the installation for the growing cycle of 49 days. The poultry houses will have high velocity ridge fans. The houses will also have gable end fans, although these are operated infrequently to maintain temperature, typically in the summer months. Biomass boilers will be used to provide hot water to heat the houses, with LPG as a stand-by fuel. After removal of the birds litter will be removed. The houses will be washed down and wash water will be collected in underground tanks. Litter, biomass boiler ash and dirty water will be spread onto land off-site and on land owned by the operator. Clean drainage water will be discharged to a swale or a ditch as shown on the site drainage plan. There are several ecological sites within the relevant screening distance of the installation, 2 Special Areas of Conservation, 1 Ramsar site, 9 Sites of Special Scientific Interest and 7 other conservation sites. 2. Industrial Emissions Directive (IED) The Environmental Permitting (England and Wales) (Amendment) Regulations 2013 were made on the 20 February and came into force on 27 February. These Regulations transpose the requirements of the IED. This permit implements the requirements of the European Union Directive on Industrial Emissions. Groundwater and soil monitoring As a result of the requirements of the Industrial Emissions Directive, all permits are now required to contain a condition relating to protection of soil, groundwater and groundwater monitoring. However, the Environment Agency’s H5 Guidance states that it is only necessary for the operator to take samples of soil or groundwater and measure levels of contamination where there is evidence that there is, or could be existing contamination and: • The environmental risk assessment has identified that the same contaminants are a particular hazard; or • The environmental risk assessment has identified that the same contaminants are a hazard and the risk assessment has identified a possible pathway to land or groundwater. H5 Guidance further states that it is not essential for the Operator to take samples of soil or groundwater and measure levels of contamination where: • The environmental risk assessment identifies no hazards to land or groundwater; or • Where the environmental risk assessment identifies only limited hazards to land and groundwater and there is no reason to believe that there could be historic contamination by those substances that present the hazard; or • Where the environmental risk assessment identifies hazards to land and groundwater but there is evidence that there is no historic contamination by those substances that pose the hazard. The site condition report (SCR) for Wotherton Farm (01/07/14) demonstrates that there are no hazards or likely pathway to land or groundwater and no historic contamination on site that may present a hazard from the same contaminants. Therefore, on the basis of the risk assessment presented in the SCR, we accept that they have not provided base line reference data for the soil and groundwater at the site at this stage. 3. Biomass boilers The application includes 4 biomass boilers. Each boiler will have a thermal input of 0.199 MW, total of ~0.8 MW. In line with the Environment Agency’s May 2013 document “Biomass boilers on EPR Intensive Farms”, an assessment has been undertaken to consider the proposed inclusion of the biomass boilers. This guidance states that the Environment Agency has assessed the pollution risks and has concluded that air emissions from small biomass boilers are not likely to pose a significant risk to the environment or human health providing certain conditions are met. Therefore a quantitative assessment of air emissions will not be required for poultry sites where: • the fuel will be derived from virgin timber, miscanthus or straw, and; • the biomass boiler appliance and installation meets the technical criteria to be eligible for the Renewable Heat Incentive, and; • the aggregate boiler net rated thermal input is less than or equal to 4 MWth, and no individual boiler has a thermal input greater than 1 MWth, and; • the stack height must be a minimum of 5 meters above the ground (where there are buildings within 25 meters the stack height must be greater than 1 meter above the roof level of buildings within 25 meters) and: • there are no sensitive receptors within 50 meters of the emission points The Environment Agency’s risk assessment has shown that the biomass boilers meet the requirements of the criteria above, and are therefore considered not likely to pose a significant risk to the environment or human health and no further assessment is required. 4. Ammonia impact assessment There are two Special Areas of Conservation (SAC) and one Ramsar site located within 10km of the installation. There are nine Sites of Special Scientific Interest (SSSI) located within 5 kilometres of the installation and 7 other conservation sites within 2km. 4.1 Ammonia Assessment – SAC / SPA / Ramsar sites The following trigger thresholds have been designated for assessment of European sites including Ramsar sites. • If the Process Contribution (PC) is below 4% of the relevant critical level (CLe) or critical load (CLo) then the farm can be permitted with no further assessment. • Where this threshold is exceeded an assessment alone and in combination is required. • An overlapping in combination assessment will be completed where existing farms are identified within 10km of the application. 4.1.1 Ammonia screening tool (v4.3) The Ammonia Screening Tool (v4.3) was used and the results are shown in the tables below. Table 1 Ammonia Emissions Site Critical Level Predicted % of Critical Ammonia µg/m3 Process Level Contribution μg/m3 The Stiperstones & The 1[1] 0.012 1.2 Hollies Mongomery Canal 1[1] 0.011 1.1 Midland Meres & Mosses 3[2] 0.086 2.9 phas 1 (Marton Pool SSSI) [1] A precautionary level of 1µg/m3 has been used during the screen. Where the precautionary level of 1µg/m3 is used, and the process contribution is assessed to be less than the 4% insignificance threshold in this circumstance it is not necessary to further consider Nitrogen Deposition or Acidification Critical Load values. In these cases the 1µg/m3 level used has not been confirmed, but it is precautionary. [2] Natural England advised, in June 2013, that a Cle of 3 µg/m3 for ammonia should be applied Table 2 Nitrogen deposition Site Critical Load kg PC Kg N/ha/yr PC % Critical N/ha/yr Load Midland Meres & Mosses 5 0.447 8.9 phase 1 (Marton Pool SSSI) Critical load taken from habitats database Table 3 Acid deposition Site Critical Load PC Kg N/ha/yr PC % Critical keq/ha/yr Load Midland Meres & Mosses No critical load - - phas 1 (Marton Pool SSSI) Critical load values taken from APIS website (www.apis.ac.uk) The process contributions are <4% of the CLe or CLo and screen out with the exception of N deposition at Midlands Meres and Mosses Ramsar site. The PC is 8.9% and there are other farms within 10km of the Ramsar, therefore this site does not screen out and detailed modelling is required. 4.1.2 Detailed modelling The applicant carried out dispersion modelling using ADMS version 5 to show nitrogen deposition compared to the critical load Table 4 Ammonia emissions Site Critical Level Predicted % of Critical Ammonia µg/m3 Process Level Contribution μg/m3 Midland Meres & Mosses 3 0.168 5.6 phas 1 (Marton Pool SSSI) Table 5 – Nitrogen deposition Site Critical Load kg PC Kg N/ha/yr PC % Critical N/ha/yr Load Midland Meres & Mosses 10 1.306 13.1 phase 1 (Marton Pool SSSI) Critical load values taken from APIS website (www.apis.ac.uk) The modelling showed that both ammonia and N deposition did not screen out. The PC is >4% and there are other farms within 10km of the Ramsar site. We carried out an audit of the modelling and looked at in-combination effects with other farms within 10km of the Ramsar: • New House Farm (EPR/GP3537TT) • Aston Hall Farm (EPR/FP3637ZV) Table 5Assessment of nutrient enrichment emissions in-combination (as based on applicants modelled figures) Farms Receptor Critical Modelled Modelled location load ΣPC PC as (kgN/ha/yr) (kgN/ha/yr) %of critical level Wotherton Farm in Midlands 10 1.9 19 combination with Aston Meres and Hall Farm and New House Mosses Farm For sites where the Predicted Environmental Concentration (PEC) (ΣPC + background) exceeds the relevant CLe or CLo, the following assumptions will be applied: • If ∑PC < 20% of CLe or CLo no further assessment is required and it is possible to conclude no adverse effect alone and in combination.